February 25, 2026

On February 24, Taiwan’s Ministry of Labor released the “Reference Guidelines on Corporate Prevention of Forced Labor” (hereinafter the “Guidelines”), with the aim of assisting Taiwanese enterprises in aligning with international standards. This development follows the September 2025 issuance of a Withhold Release Order (WRO) by U.S. Customs and Border Protection against products manufactured in Taiwan by the well-known bicycle brand Giant, as well as the recently concluded U.S.–Taiwan trade agreement, which includes a commitment by Taiwan to prohibit recruitment fees for migrant workers in the manufacturing and fishing sectors within three years. Together, these developments represent concrete governmental responses to longstanding labor conditions and human rights concerns in Taiwan’s manufacturing industry.

The Guidelines highlight three key points. First, they make clear that human rights issues in supply chains are no longer merely ethical concerns, but have evolved into significant risks affecting corporate operations and reputation—particularly as major trading partners of Taiwan enact legislation requiring companies to implement human rights due diligence across global supply chains, or impose restrictions and bans on products associated with forced labor. To address this, the government draws upon both domestic and international legal frameworks to explain the regulation of forced labor, and provides past domestic case examples to assist Taiwanese enterprises in establishing mechanisms to prevent forced labor and keep pace with international labor standards.

Second, the Guidelines adopt the eleven indicators of forced labor identified by the International Labour Organization (ILO) in 2012. Most notably, they emphasize debt bondage (Indicator No. 9) as a core issue of forced labor, illustrated through a concentric-circle model. Debt weakens workers’ ability to leave exploitative conditions and reinforces other coercive mechanisms such as deception, violence, or control. This model underscores that forced labor rarely manifests through a single indicator, but rather through the interaction of multiple forms of systemic exploitation. Accordingly, implementing “fair recruitment” and the “employer-pays” (zero recruitment fee) principle is key to preventing workers from falling into debt bondage and becoming vulnerable to forced labor.

Finally, in light of the complexity of forced labor and Taiwan’s historically narrow understanding of the issue, the Guidelines also provide practical references for corporate action. These include recommendations on internal prevention planning, as well as examples of how various forced labor indicators may manifest in practice. The aim is to offer Taiwanese enterprises a solid operational foundation for addressing forced labor risks.

We welcome the issuance of these Guidelines and the Taiwanese government’s evolving interpretation of forced labor. At the same time, effective implementation and oversight remain the greatest challenges in preventing forced labor. It is hoped that in the coming year, business and human rights in Taiwan will see more concrete progress.